S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-No conflict between provision of DTAA between India and Netherlands-Non-discrimination and there was no ambiguity in classification and rates of tax, assessee, which is not a ‘domestic company’, is liable to tax at rates prescribed for a company ‘other than a domestic company’-DTAA-India-Netherlands. [S. 2(17), 2(23A), 90, Art. 24(2)]